Credit unions were proud of the thousands of letters they generated about NCUA's proposed rule on risk-based capital, and not without reason. Now, the bankers are taking a page from the CU handbook, sending scads of letters to the agency bemoaning its proposed revision of the member business lending rule.

It would be easy to dismiss this as no big deal. Indeed, in a poll that was still live on at press time, 65% of respondents said the fact the majority of the letters filed with NCUA (as of July 31) were from banks was "no big deal," with just 35% saying CUs had better get to work on filing comments of their own (see graphic at right).

But CUs might not want to be so quick to shrug this off. CUs are pretty happy with the proposed changes. This explains the relative lack of letters: we tend to be far quicker to complain than to compliment.

And, as former NCUA Chairman Dennis Dollar notes in our story about the flood of banker comments on the rule, the agency likely will take what the bankers say with a healthy grain of salt. After all, that bankers don't like this rule isn't news.

Still, one of the mistakes CUs have often made is allowing banks to drive the message, allowing banks to set the agenda, forever playing defense to the banker offense.

If mimicry is the greatest compliment, banks' copying the CU advocacy manual and sending all those letters to NCUA is a rather flowery homage to CUs. But you can be sure they wouldn't be adopting a measure they didn't think was effective.

All the more reason CUs might want to sharpen up those pencils after all.

Editor in Chief Lisa Freeman can be reached at